Worcester Regional Transit Authority Limited English Proficiency/Language Assistance Plan
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
Worcester Regional Transit Authority Limited English Proficiency/Language Assistance Plan February 2018
Contents Accessible Formats ........................................................................................2 Foreword........................................................................................................3 Glossary of Terms ..........................................................................................4 1.0 INTRODUCTION .....................................................................................7 2.0 FOUR-FACTOR ANALYSIS ..................................................................... 10 2.1 Factor 1: Proportion, Number, and Distribution of LEP Persons ............ 10 2.1.1 Service Area Geographic Boundaries .................................................... 11 2.1.2 Analysis of Language-related Data....................................................... 11 2.1.2.1 Number/Proportion of LEP Persons Eligible to Be Served In WRTA Service Area ........................................................................................................... 11 2.1.2.2. Number/Proportion of LEP Persons Eligible to Be Served In WRTA Fixed- Route Service Area ....................................................................................... 14 2.1.2.3 Number/Proportion of Persons Likely to Be Encountered by the Program or Grantee ...................................................................................................... 15 2.1.2.4 Nature of Interactions with LEP individuals ........................................... 16 2.1.3 Involvement of Community Organizations and Committees..................... 20 2.2 Factor 2: Frequency of Contact with LEP Persons ................................. 25 2.3 Factor 3: Nature and Importance of WRTA Services to the LEP Community ................................................................................................... 25 2.4 Factor 4: Resources Available to WRTA and Overall Cost...................... 26 3.0 SAFE HARBOR PROVISION ................................................................... 27 4.0 LANGUAGE ASSISTANCE IMPLEMENTATION PLAN ............................... 29 4.1. Identifying LEP Persons Who Need Language Assistance ...................... 29 4.2. Providing Language Assistance ............................................................. 29 4.2.1 Existing LEP Programs and Services ..................................................... 30 4.2.2 Future Language Assistance Program Services ...................................... 32 4.2.3 WRTA LEP Coordination with Regional MPO ........................................... 33 4.3. Training Staff ........................................................................................ 34 4.4. Providing Notice to LEP Persons ............................................................ 35 4.5. Monitoring and Updating The LAP .......................................................... 37 Appendices 1 | Page
Accessible Formats This document is available in accessible formats upon request. Paper copies of this document and additional information about accessible formats may be obtained by contacting the Worcester Regional Transit Authority at: 60 Foster Street, Worcester, MA 01605 (508) 791-WRTA (9782) www.therta.com • Arabic: ""أذا أردت ترجمة هذة المعلومة للغة أخرى اضغط على مفتاح جوجل فوق • Chinese: 如果此信息需要用另一种语言,请点击谷歌翻译的上述特征。 • Polish: W celu przetłumaczenia powyższego tekstu należy skorzystac z translatora Google. Link do translatora znajduje sie powyżej. • Portuguese: Caso essa informação seja necessária em outro idioma, favor clicar no link do tradutor da Google acima. • Spanish: Si necesita esta información en otro idioma, por favor use la herramienta de “Google Translate” ubicado arriba en esta página. • Swahili: Kama unahitaji habari hii katika nyingine lugha, unaweza kubonyeza mahali panaandikwa “Google Translate” hapa juu. • Vietnamese: Nếu thông tin này cần được xem trong ngôn ngữ khác, xin vui lòng chọn tính năng Google Translate ở trên 2 | Page
Foreword This Plan was prepared by the Transit staff of the Central Massachusetts Regional Planning Commission (CMRPC) under contracts effective through 07/01/16 through 06/30/17, and 07/01/17 through 06/30/18 with the Worcester Regional Transit Authority (WRTA), with information provided by the WRTA. Funding for preparation and administration of this Plan is sourced from the Federal Transit Administration (FTA) and the Commonwealth of Massachusetts under various contracts. This Plan supersedes the WRTA’s Limited English Proficiency Plan dated April 2015. It is intended to dovetail with the work of the Central Massachusetts Metropolitan Planning Organization (CMMPO) and its Limited English Proficiency – Language Assistance Plan and Title VI Plan. 3 | Page
Glossary of Terms American Community Survey (ACS): an ongoing U.S. Census Bureau survey. The ACS contains information previously captured only in the long form of the decennial census, such as ancestry, educational attainment, income, language proficiency, migration, disability, employment, and housing characteristics. The ACS is updated annually and is a source of information for the WRTA LEP Analysis – Language Assistance Plan. Central Massachusetts Transit Management Services, Inc. (CMTM): WRTA contracts with CMTM to operate its fixed-route bus services. Environmental Justice (EJ): For matters involving transportation in Massachusetts, EJ analyses identify specific populations that are vulnerable to discrimination and determine whether a project (or service) would not disproportionately impact these populations. An EJ population is identified as a neighborhood containing a certain percentage of minority, low-income, foreign-born, or limited English proficiency (LEP) residents.1 Language Assistance Plan (LAP): The LAP details the WRTA’s actions for ensuring that its programs and services are accessible to persons with limited English proficiencies. Limited English Proficiency (LEP): Federal Executive Order 13166 requires Federal funding recipients such as the WRTA to: 1. Describe services provided; 2. Describe the language needs in the population and/or area in which the federally funded program applies; 3. Document how its existing language accommodations meet the needs of the population served, and 4. Identify unmet needs for services to those with limited English proficiency (LEP) and develop a Language Assistance Plan (LAP) to address those unmet needs. 1 Massachusetts Executive Office of Energy and Environmental Affairs, Environmental Justice Policy. 4 | Page
Central Massachusetts Metropolitan Planning Organization (CMMPO): a transportation policy-making body made up of representatives from local government and transportation agencies. CMRPC is one member of that ten- member group, and CMRPC provides staff and transportation planning functions for the CMMPO. Central Massachusetts Regional Planning Commission (CMRPC): CMRPC provides transportation planning services for the City of Worcester and 39 surrounding communities in the southern two-thirds of Worcester County. The CMRPC’s transit staff conduct the WRTA’s service planning activities, including assistance with WRTA public participation, Title VI, and language assistance. Federal Transit Authority (FTA): a U.S. Department of Transportation agency that provides financial and technical assistance to local public transit systems. State Fiscal Year (FY): July 1 of current year to June 30 of following year Geographic Information System (GIS): a system designed to capture, store, manipulate, analyze, manage, and present spatial or geographic data. Limited English Proficient (LEP): defined here as a person or a population who may speak a language other than English at home and self-reports that they speak English ‘less than very well’, ‘not well’, or ‘not at all’. Language Assistance Plan (LAP): paired with the LEP Analysis, the LAP summarizes an FTA Recipient’s policies, procedures and activities to make FTA-funded activities accessible to LEP populations. Low-Income Households: defined in the CMMPO region using American Community Survey (ACS) Five-Year Estimates data as those earning equal to or less than 65% of the region’s median income. Massachusetts Department of Transportation (MassDOT): the Commonwealth’s transportation organization. Its Rail & Transit Division oversees WRTA administration and operation, and coordinates its planning and funding activities to ensure compliance with federal policies and regulations. 5 | Page
Minority: a person who is a citizen or lawful permanent resident of the United States and who is: ● Black: a person having origins in any of the black racial groups of Africa; ● Hispanic: a person of Mexican, Puerto Rican, Cuban, Central or South American, or other Spanish culture or origin, regardless of race; ● Asian or Pacific Islander: a person having origins in any of the original peoples of the Far East, Southeast Asia, Indian Subcontinent, or the Pacific Islands, or ● American Indian or Alaskan Native: a person having origins in any of the original peoples of North American, and who maintain cultural identification through tribal affiliation or community recognition. National Transit Database (NTD): an FTA system for recording U.S. transit systems’ financial, operating, and asset information. Supports local, state and regional planning efforts and helps governments and other decision-makers make multi-year comparisons and perform trend analyses. MassDOT Office of Diversity and Civil Rights (ODCR): oversees WRTA Title VI / Nondiscrimination activities conducted by WRTA in-house and by CMRPC Transit Unit staff. Paratransit Brokerage Services Transit Management Services, Inc. (PBSTM): PBSTM, under contract to the WRTA, operates the WRTA’s paratransit services. Public Participation Plan (PPP): a plan detailing strategies to engage the public, including minority and limited English proficient (LEP) populations, in planning and programming activities. Worcester Regional Transit Authority (WRTA): a Regional Transit Authority established in 1974 under Chapter 161b of the Massachusetts General Laws to develop, finance, and contract for the operation of public transportation facilities and services within its Service Area. The WRTA Service Area comprises 37 communities in Central Massachusetts. 6 | Page
1.0 INTRODUCTION This Limited English Proficiency (LEP) Analysis / Language Assistance Plan (also referred to as LEP Plan) has been developed consistent with FTA Circular 4702.1B, “Title VI Requirements and Guidelines for Federal Transit Administration Recipients,” published October 1, 2012. This plan is a living document; it is continually reviewed, updated and improved to help better meet the needs of transit customers in the WRTA Service Area. This Plan describes the WRTA’s strategy for delivering improved services to persons who speak English less than very well – that is, those persons whose proficiency in English is limited or nonexistent. The WRTA’s goal is to ensure that LEP persons have meaningful access to its information, services, and benefits. This Plan documents the WRTA’s fulfillment of specific responsibilities as a U.S. Department of Transportation funding recipient, including: • Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, et seq., and its implementing regulations, which state that no person shall be subjected to discrimination on the basis of race, color, or national origin under any program or activity that receives federal financial assistance. • Executive Order 13166 “Improving Access to Services for Persons With Limited English Proficiency'' of August 16, 2000, which directs that Federal agencies subject to the requirements of Title VI publish guidance for their recipients clarifying LEP obligations. Executive Order 13166 directs that all guidance documents be consistent with the compliance standards and framework detailed in the U.S. Department of Justice’s Policy Guidance “Enforcement of Title VI of the Civil Rights Act of 1964—National Origin Discrimination Against Persons With Limited English Proficiency.” This guidance advises that different treatment based upon a person’s inability to speak, read, write, or understand English may be a type of national origin discrimination. Executive Order 13166 applies to all federal agencies, programs and operations of entities that receive funds from the federal government, which includes the WRTA. 7 | Page
These federal regulations and guidance define persons with Limited English Proficiency as individuals with a primary or home language other than English who must, due to limited fluency in English, communicate in that primary or home language if the individuals are to have an equal opportunity to participate effectively in or benefit from any aid, service or benefit in federally funded programs and activities. The WRTA makes this Plan available to all persons and organizations, including those for whom LEP may be a common consideration, including social service, non-profit, and law enforcement agencies. This Plan is available in electronic PDF format on the WRTA website at www.therta.com. Paper copies of this Plan will be provided to the members of the Central Massachusetts Metropolitan Planning Organization (CMMPO), the Massachusetts Department of Transportation, Federal Highway Administration, the Federal Transit Administration, the Central Massachusetts Regional Planning Commission, and any other person or agency requesting a copy. Since this Plan’s last update, the WRTA has: • created a ‘language line’ with direct service to a translation agency through the WRTA Hub Customer Service Center; • trained Customer Services and Operations staff on language encounters and best practices; • implemented use of an I-Tablet and the Google Translate tool at Customer Services to assist customers in communicating; • incorporated Notices of Language Assistance Availability into existing outreach which have been; • created a Spanish version of the WRTA System Map, which has been made available and posted at the WRTA Hub, and • implemented a WRTA website Google Analytics tool to monitor site content effectiveness and Google Translate tool usage. 8 | Page
Figure 1: WRTA Fixed-Route Bus Service and Service Area Member Communities 9 | Page
2.0 FOUR-FACTOR ANALYSIS This Plan utilizes the FTA-recommended Four-Factor Analysis described in an FTA publication of April 13, 2007 entitled, “Implementing the Department of Transportation’s Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient (LEP) Persons: A Handbook for Public Transportation Providers.” The WRTA’s prior experience with LEP individuals is longstanding. The WRTA Service Area includes communities with diverse ethnicities, including many people for whom English is not their native language. WRTA employees and operators are also an ethnically diverse group, of which many individuals share cultural backgrounds with ethnic groups in the Service Area. This personal experience and connection with local communities is one of the most regular and important ways that the WRTA maintains its sensitivity to the concerns of LEP persons. In accordance with FTA guidance, this Section analyzes each of the following four factors to determine the level and extent of language assistance measures required to sufficiently ensure meaningful access to public transit services within the WRTA service communities. These factors are: Factor 1: Proportion, Numbers and Distribution of LEP Persons in the WRTA Service Area Factor 2: Frequency of Contact with LEP Persons Factor 3: Nature and Importance of WRTA Service to LEP Persons Factor 4: Resources Available to WRTA and Cost In addition, the WRTA’s Language Assistance Plan (Section 4.0 of this Plan) details measures that the WRTA staff is or will be implementing. 2.1 Factor 1: Proportion, Number, and Distribution of LEP Persons In 2010, the U.S. Census Bureau ceased asking the three questions related to language spoken at home and the ability to speak English for the population 5 years of age and older. The American Community Survey (ACS) is now responsible for generating sample data in one, three and five- year periods depending on the population size of a given geographical area. The five-year period survey is comparable to the 2000 U.S. Census long form sample products. The four distinctions of level of proficiency that the Census used in the past are now reduced to two levels of proficiency: “Speak English Very Well” and “Speak English Less than Very Well”. The latter proficiency distinction includes persons who reported speaking 10 | P a g e
English “well”, “not well”, and “not at all”. Data used for this Plan was obtained from the 2011-2015 American Community Survey (ACS) Five-Year Estimates, concurrent with use of this same dataset by the Central Massachusetts Metropolitan Planning Organization (CMMPO). Persons who are reported in the 2011-2015 ACS to speak English “less than very well” are considered to be limited English proficient persons. 2.1.1 Service Area Geographic Boundaries The WRTA Service Area consists of the 37 municipalities listed in Table 1 below and shown in Figure 1 on Page 3, above: Table 1: WRTA Service Area Municipalities Auburn Grafton Oakham Warren Barre Holden Oxford Webster Berlin Holland Paxton Westborough Boylston Leicester Princeton West Boylston Brimfield Millbury Rutland West Brookfield Brookfield New Braintree Shrewsbury Worcester Charlton Northborough Southbridge Clinton Northbridge Spencer Douglas North Brookfield Sturbridge Dudley Millbury Sutton East Brookfield New Braintree Wales The WRTA Service Area’s 2011-2015 ACS population estimate was 539,127, or 8.1% of the 2011-2015 ACS total population estimate for Massachusetts (6,627,768). 2.1.2 Analysis of Language-related Data The WRTA has utilized ACS 2011-2015 five-year estimates of demographic data for the WRTA’s 37 communities (‘Service Area’) covered by this Plan. A comparison of four statistics obtained from the 2011-2015 ACS with like statistics from the 2010 Census are presented in Table 1 on Page 6, below. 2.1.2.1 Number/Proportion of LEP Persons Eligible to Be Served In WRTA Service Area The estimated total population five years of age and older within the WRTA Service Area is 507,889, an increase of 6,083 persons or 1.2% from the 2010 Census. Of this total, the estimated proportion of the population that speaks only English declined to just below 80% while the estimated proportion of those who speak languages other than English at home increased to just 11 | P a g e
above 20%. Of those who speak other languages at home, 44,891 (8.8%) are estimated to speak English ‘less than very well’: these persons comprise the LEP population within the WRTA Service Area as shown in Table 2 below: Table 2: WRTA Service Area Total Population/English/Other Languages/English Proficiency – 2010 Census and 2011-2015 ACS Total Percent Total Percent (2010) (2010) (2011-2015) (2011- 2015) Total Population 5 501,806 100% 507,889 100% years and over English only 402,013 80.1% 402,276 79.2% Languages other than 99,793 19.9% 105,613 20.8% English Speak English "less 42,263 8.4% 44,891 8.8% than very well" Again using the 2011-2015 ACS, we can provide additional detail for the population speaking languages other than English in the WRTA Service Area as shown in Table 3 below: Table 3: WRTA Service Area Breakdown of Language Spoken at Home and English Proficiency by Language Category - 2011-2015 ACS Speak English less Language Total Percent than "very well" Languages other than English 105,613 20.70% 42,263 8.40% SPANISH OR SPANISH CREOLE 42,578 8.38% 18,504 3.64% OTHER INDO-EUROPEAN 33,316 6.56% 12,034 2.37% LANGUAGES French (incl. Patois, Cajun): 4,298 0.85% 992 0.20% French Creole: 1,067 0.21% 381 0.08% Italian: 1,673 0.33% 357 0.07% Portuguese or Portuguese 5,842 1.15% 2,700 0.53% Creole: German: 993 0.20% 90 0.02% Yiddish: 5 0.00% 0 0.00% Other West Germanic 170 0.03% 0 0.00% languages: Scandinavian languages: 189 0.04% 44 0.01% Greek: 2,156 0.42% 769 0.15% 12 | P a g e
Table 3: WRTA Service Area Breakdown of Language Spoken at Home and English Proficiency by Language Category - 2011-2015 ACS (continued from previous page) Speak English less Language Total Percent than "very well" Russian: 1,740 0.34% 772 0.15% Polish: 3,027 0.60% 1,149 0.23% Serbo-Croatian: 212 0.04% 19 0.00% Other Slavic languages: 263 0.05% 93 0.02% Armenian: 361 0.07% 104 0.02% Persian: 510 0.10% 220 0.04% Gujarati: 1,080 0.21% 626 0.12% Hindi: 1,906 0.38% 507 0.10% Urdu: 790 0.16% 130 0.03% Other Indic languages: 2,941 0.58% 1,204 0.24% Other Indo-European 4,093 0.81% 1,877 0.37% languages: ASIAN AND PACIFIC ISLAND 18,004 3.54% 9,682 1.91% LANGUAGES Chinese: 5,284 1.04% 3,023 0.60% Japanese: 341 0.07% 152 0.03% Korean: 401 0.08% 244 0.05% Mon-Khmer, Cambodian: 566 0.11% 180 0.04% Hmong: 16 0.00% 0 0.00% Thai: 240 0.05% 209 0.04% Laotian: 386 0.08% 248 0.05% Vietnamese: 6,822 1.34% 4,415 0.87% Other Asian languages: 3,496 0.69% 1,088 0.21% Tagalog: 328 0.06% 78 0.02% Other Pacific Island languages: 124 0.02% 45 0.01% ALL OTHER LANGUAGES 11,715 2.31% 4,671 0.92% Navajo: 39 0.01% 0 0.00% Other Native North American 46 0.01% 0 0.00% languages: Hungarian: 146 0.03% 9 0.00% 13 | P a g e
Arabic: 3,299 0.65% 1,543 0.30% Table 3: WRTA Service Area Breakdown of Language Spoken at Home and English Proficiency by Language Category, 2011-2015 ACS (continued from previous page) Speak English less Language Total Percent than "very well" Hebrew: 211 0.04% 33 0.01% African languages: 7,610 1.50% 2,891 0.57% Other and unspecified 364 0.07% 195 0.04% languages: Using the above ACS data to measure ability to speak English “less than very well”, six specific languages (Arabic, Chinese, Polish, Portuguese, Spanish, and Vietnamese) rise to the top and meet the Safe Harbor threshold of 1,000 persons in the WRTA Service Area at this time. In further detail, and specific to those persons who speak Spanish, which is the largest language group spoken at home besides English, the ACS estimates that only 3.6% speaks English ‘less than very well’. Of the 2.3% that speak Other Indo-European languages at home and speak English ‘less than very well’, Portuguese comprised 0.5%, and Polish comprised 0.3%. Within the Asian languages, Chinese (0.6%) and Vietnamese (0.9%) had the largest proportion of the 1.9% who speak English “less than very well”. Similarly, this happens with the All Other Languages category, with the African languages being 0.6% of 0.9% for the category but Arabic as a single language exceeding the Safe Harbor threshold, at 1,543 (though 0.3% of all speakers in this category). 2.1.2.2 Number/Proportion of LEP Persons Eligible to Be Served In WRTA Fixed-Route Service Area The WRTA Fixed-Route Service Area is contained within the overall WRTA Service Area. It is defined as the area within one quarter-mile from a transit route. The total population 5 years old and over in the WRTA Fixed-Route Service Area is 357,314. Of these persons, 75.2% speak only English at home. The top languages other than English spoken at home in the WRTA Fixed- Route Service Area are very similar to the top languages spoken in the region. Spanish is, by far, the language most frequently spoken other than English (10.4%), followed by African languages (2.0%), Vietnamese (1.8%), Portuguese (1.3%), Chinese (1.1%) and French (0.9%). 14 | P a g e
2.1.2.3 Number/Proportion of Persons Likely to Be Encountered by the Program or Grantee The ACS data, combined with Customer Services and Operations data including surveys and logs of actual encounters, forms the basis of this part of the LEP analysis. In the WRTA Service Area the most prominent language besides English that is spoken at home is Spanish (8.3%). The proportion of Other Indo-European languages spoken at home is 6.5% with Portuguese and French (1.1%) having the largest proportion, followed by Polish (0.7%). In relation to the Asian and Pacific Island languages, Vietnamese (1.1%) and Chinese (0.9%) show the largest proportion of the 3.1% in this language category. All other languages comprised 2.0%, of which African languages is 1.4%. The next consideration is the identification of persons speaking English less than very well in the WRTA Service Area and in Census block groups intersecting WRTA Fixed Routes as shown in Table 4 below: Table 4: Native Language of Persons Speaking English Less Than "Very Well", WRTA Service Area and Block Groups Intersecting WRTA Fixed Routes Persons Speaking English less than "Very Well" Block Groups Language or Language Group WRTA Service intersecting Area WRTA Fixed Routes Spanish or Spanish Creole 18,504 17,383 Vietnamese 4,415 4,300 Chinese 3,023 2,436 African languages (incl. Swahili) 2,891 2,765 Portuguese or Portuguese Creole 2,700 2,413 Other Indo-European languages (incl. Afrikaans, Bosnian, Greek, German, Albanian) 1,877 1,812 Arabic 1,543 1,340 Other Indic languages (Hindi, Gujarati) 1,204 1,117 Polish 1,149 753 Other Asian languages (incl. Khmer) 1,088 713 French (incl. Patois, Cajun) 992 783 Source: 2015 5 Year American Community Survey, 2011 - 2015. Table B16001 Limited English Proficiency 15 | P a g e
As shown in Table 4 above, both of the geographic areas calculated are important. However, the block groups intersected by WRTA fixed routes have the highest probability for WRTA language interactions, as they are the areas likely to capture most (if not all) WRTA riders on both the fixed route and paratransit services. Using this measure, eight languages/language groups exceed the Safe Harbor threshold for the WRTA fixed-route service area. It is important to note that both “African Languages”, “Asian Languages”, and “Indo-European” language groups comprise many different languages. Because of this, it has been unclear what specific languages should be targeted within the 1,000 persons Safe Harbor threshold – and, what specific languages the WRTA would focus upon on a case-by-case basis. Using a combination of Census, ACS data and staff interactions, the WRTA has included these three additional language groups: • African Languages: Swahili • Indo-European: Albanian • Asian: Chinese and Vietnamese Language studies involving proficiency among various linguistic groups support that there are significant proficiency variations according to individuals’ exposure to English in their home environment and/or economic and educational skill attainment. With respect to the Asian Languages, of the top languages that meet the 1,000 person threshold, the Vietnamese population aged 5 years and over is the most “vulnerable” since 64.7% of the population that speaks Vietnamese at home speaks English “less than very well” (4,415 of 6,822 that speak Vietnamese at home). Note that the ACS-estimated percentage of persons speaking Vietnamese at home who report that they are limited English proficient is lower than the WRTA reported in 2015 using 2010 Census data (66.0%). 2.1.2.4 Nature of Interactions with LEP individuals WRTA interactions with the general public (including LEP individuals) occur at four key intake points, in descending order of frequency: • Customer Services office staff; • Operations (bus operators); • Administration, Customer Services and Operations staffs (public meetings), and • WRTA website. 16 | P a g e
Customer Services served an average of 78,573 persons each FY during FYs 2014-2017, peaking at 85,406 persons in FYs 2015-2016. As would be expected, general activity increases correspond to periods in which services are extended or reduced. The staff believes that the increase in overall activity between FYs 14-16 is attributable to the implementation of several new routes during that period. Staff recorded general inquiries, fare information, and schedule information as the top issues encountered overall. WRTA estimated in its previous Plan that it served approximately 10-15 LEP persons per day at the window. In addition, staff estimated that it fielded 2-5 LEP callers per day in 2015. In January 2018, the staff estimated that they handled approximately 7 Spanish-speaking callers per day, in addition to Customer Services’ paratransit reservationists assisting on average one to two LEP customers per month. Staff periodically samples language encounters at the window to monitor overall volume, and to observe changes. Samples collected prior to 2015 indicated that between 40 and 50 percent of all visitors to the Customer Service Office spoke a language other than English. A comparison of samples collected in September-October 2015 and January 2018 again yielded Spanish as the highest language encounter, followed by Vietnamese as shown in Table 5 below: Table 5: WRTA Samples of Customer Service Interactions by Languages Other Than English 09/14/15 - 10/10/15 01/02/18 – 01/31/18 Language # % # % Albanian 1 0.3 11 1.4 Arabic 2 0.6 4* 0.8 Bosnian+ 0 0 1 0.2 Chinese 1 0.3 1 0.2 French 46 15 0 0 French Creole 22 7.2 0 0 Polish 2 0.6 5 1.0 Portuguese 0 0 0 0 Spanish 229 74.6 408 82.4 Swahili 0 0 4 0.8 Vietnamese 3 0.9 26 5.3 Other 1 0.3 35 7.0 Total 307 495 +Indo-European language 17 | P a g e
*includes 1 interaction recorded as Farsi Within Operations, the bus operators are often the ‘front line’ for many LEP customers. Information collected by WRTA Operations Staff are shown in Table 6 below: Table 6: WRTA Bus Operator Language Interactions # of interactions, Routes on which drivers report 2/1 – 2/9, 2018 specific language interactions Albanian 16 3,6,11,14,24 Arabic 3 2,6,15,24,31 Swahili 8 4,19,30,31 Chinese 7 3,5,15,19,27,30,42 French 1 3,4,19 French Creole 1 4,11,33 Greek 1 6,31,42 Polish 2 1,2,5,6,14,15,24,25 Portuguese 6 11,16 Spanish 27 1,3,4,5,7,11,26,27,30,42 Vietnamese 6 1,23,27 Other 3 2,14,15,23,31 Total 81 Operator/passenger interactions most frequently occur at the bus door, followed by Hub platform interactions. This can be a challenging context for communication in any language. Anecdotal information supports that most interactions involved questions about the route (if, when, or where a bus will stop), or questions about fare payment. Interactions at the Hub bus platforms involve operators, starters, and supervisory personnel. WRTA passenger surveys are also considered when assessing the likelihood of encounters in certain languages. Print versions were circulated and posted in English and Spanish, and written translations were offered in other languages upon request. A 2016 fixed-route survey offered in English and Spanish yielded 440 responses, of which 22, or 5% were completed in Spanish. Compare with a 2017 paratransit survey, which yielded 230 responses, 8 in Spanish and 6 in Vietnamese. Please refer to Appendix J of WRTA’s 2018 Title VI Plan to view the most recent fixed-route and paratransit customer surveys. WRTA website Google Translate use was also considered as a potential indicator of the likelihood and frequency of Program/Service contact with LEP 18 | P a g e
individuals. The WRTA hosts a main website for its overall organization and services, www.therta.com. For the FYs 2014-2017 period, Google Translate was used in less than 1% of all WRTA website visits. When used, visitors most frequently employed it to translate website content into Spanish. Google Translate language translations that trended upward in the same period (though in far fewer numbers than Spanish) were Arabic, Chinese and Vietnamese. Google Translate usage for Afrikaans, Albanian, French, German, Italian, Polish, Portuguese, Russian trended downward, and each language constituted less than 10% in any given FY. However, the staff observed that over the same period Google Translate was used to translate a progressively wider range of individual languages- from nine in FY 2014 to fifteen in both FYs 2016 and 2017. The WRTA also hosts a separate paratransit website, for which the following translation activities were tracked: • FY2016: 23 translations – Spanish, 11 (47.8%); Polish, 6 (26.1%); Albanian, 5 (21.7%), and Afrikaans, 1 (4.3%). • FY2017: 27 translations – Spanish, 21 (77.8%); Portuguese & Vietnamese, unspecified. The WRTA has in the past anticipated that its Service Area’s minority (and LEP) population will continue to grow. Its geography, comparatively lower housing and other living costs compared to regions closer to Boston, and diversity of business and employment are factors. In particular, this growth is expected to occur in the City of Worcester, which is considered New England’s central city. It is also growing in some of the Service Area’s smaller communities proximate to I-495, in Greater Southbridge, and at the western edge along MA Route 9. In 2010, the minority population in the WRTA Service Area represented 23.2% of the total population, showing a 42.6% increase between 2000 and 2010. However, the 2011-2015 ACS estimates suggest that the Service Area’s minority population may be declining while its population of Hispanic origin continues to grow. The mix of ethnicities and languages spoken in the Service Area is transitioning, and some of the languages other than English that have long been spoken at home in the Service Area (i.e. Polish and French) may continue to decline. USDOT guidance specifies circumstances that signify strong evidence of a Recipient’s compliance with its written translation obligations. If a Recipient provides written translations of Vital Documents into languages that meet certain thresholds—called “Safe Harbor languages”—then its obligation is likely considered met. Safe Harbor languages are non-English languages spoken by 19 | P a g e
LEP persons (of those eligible to be served of likely to be affected or encountered by the Recipient) who comprise at least 5% of the population expected to be encountered by the Program or service, or 1,000 individuals, whichever is less. As always, the cost of translating materials into many different languages is prohibitive; therefore, the WRTA prioritizes preparation of written translations into the languages it most frequently encounters. The WRTA is always prepared to provide written translations in languages less frequently encountered. At present, the WRTA is relying upon the combination of Census and ACS data with documented Customer Services and Operations encounters to establish its list of Safe Harbor languages. Accordingly, at this time the CMMPO is focusing its language outreach and assistance resources on these languages: Arabic, Chinese, Polish, Portuguese, Spanish, and Vietnamese. Refer to Appendix B to review the WRTA Vital Documents Summary & Notice of Language Availability. 2.1.3 Involvement of Community Organizations and Committees The WRTA is engaged with community-based organizations that serve LEP persons in two general ways: 1) participating in meetings of organizations and agencies that deal with LEP issues; and 2) participating in the public outreach activities of the Central Massachusetts Metropolitan Planning Organization (CMMPO). The WRTA has participated on an ongoing basis in the meetings and activities of the following community and municipal organizations that address in part the needs of LEP persons: • Ascentria (particularly for one-on-one travel training and system orientations) • Central Massachusetts Workforce Investment Board • Community organizations, including: Centro, Worcester Community Connections & Worcester Connections Family Resource Center of YOU, Inc., Neighbor 2 Neighbor, the African Community Education and the Southeastern Asian Coalition to assist in public outreach and providing feedback • Councils on Aging Directors in WRTA communities The WRTA also continues to work with the CMMPO to identify organizations not traditionally engaged with LEP persons. The following list outlines the various organizations with which the WRTA has contacted and/or engaged relevant to LEP populations in its Service Area: 20 | P a g e
Annual CMMPO Environmental Consultation Session • US Environmental Protection Agency (EPA), Region 1 • Federal Highway Administration, MA Division • MA Department of Environmental Protection (DEP) • MA Department of Conservation & Recreation (DCR) • MA Riverways Program • MassDOT Stormwater Program • University of Massachusetts, Amherst • Conservation Law Foundation (CLF) • P&W Railroad (Genesee and Wyoming Railroad as of 2016) • Town of Spencer • The Nature Conservancy • MAPC Environmental & Climate Change • Regional Environmental Council (REC) • John H. Chafee Blackstone River Valley National Heritage Corridor Commission • Blackstone River Coalition • Blackstone Canal Conservancy • Uxbridge Conservative Club • Friends of Upton State Forest • Massachusetts Audubon Society • Quaboag/Quacumquasit Lake Association (QQLA) • Blackstone River Watershed Association (BRWA) • Spencer Conservation Commission Environmental Justice • Worcester Community Connections • TPAG • Central Massachusetts Workforce Investment Board • South Sudan-American Friendship and Trade Association (SSAFTA) Freight • Growth Options for the 21st Century (GO21), railroad advocacy group • New England Rail Expo, Grafton & Upton Railroad • State Rail Plan public meetings • Former Providence & Worcester Railroad (now Genesee and Wyoming 21 | P a g e
Railroad) • MassCentral Railroad Ribbon Cutting Ceremony, South Barre, • New England Automotive Gateway (NEAG) intermodal facility, East Brookfield/Spencer • Regional Freight Advisory Committee meetings Health • Mass. In Motion • Edward M. Kennedy Community Health Center, Worcester • Worcester Refugee Mental Health • Milford Regional Medical Center • Golden Life Board and Care Home Bicycle & Pedestrian • Bicycle & Pedestrian Task Force • Bay State Trail Riders Association • Dudley Trails and Greenways Land Use • Mendon Land Use • Representatives and planners from the towns of Sturbridge, Spencer, Holden, Millbury, Douglas, Dudley, Leicester, Auburn, Northbridge, Mendon, West Boylston, Oxford, Charlton, Paxton, Warren, Worcester, Blackstone • Dudley Conservation Land Trust • Upton Open Space • Metacomet Land Trust • Common Ground Land Trust • Opacum Land Trust Economic Development • Worcester Office on Economic Development • CMRPC Regional Planners Forum • Worcester Regional Chamber of Commerce • Blackstone Valley Chamber of Commerce • Massachusetts Executive Office of Housing and Economic Development (EOHED) • Chamber of Central Mass South (CMS Chamber) 22 | P a g e
• Worcester Business Development Corporation • Dudley Economic Development Committee • Worcester Regional Research Bureau (WRRB) Legislative • U.S. Congressional Delegation, including Representative James McGovern • Central Massachusetts Legislative Delegation Academic Institutions, Including: • Assumption College • Becker College • Clark University • Massachusetts College of Pharmacy and Health Sciences • Quinsigamond Community College (QCC) • The College of the Holy Cross • Worcester State University (WSU) • Worcester Polytechnic Institute (WPI) • UMass Medical School Central Regional Homeland Security Advisory Council (Worcester County) Spotlight: WRTA Public Outreach Practice Examples In the 2015 Plan, we described the Massachusetts Department of Public Health “Neighborhood Conversations” initiative, which was active in the summers of 2013 and 2014. CMRPC staff on the Transportation Subcommittee requested that general transportation need questions (including transit) be included as part of the Neighborhood Conversations: Neighborhood Conversations Participants (2013 and 2014) African Community Education Albanian Rescue League Worcester City Councilors Belmont Hill Seniors Children’s Friend: School Age Mothers Program Evangelical Church – Community Health Fair Family Fun Friday Foundation for Suicide Prevention 23 | P a g e
Granby Street Youth Group Green Hill Park Neighborhood Green Island Iraqi Women’s group Ivy Child Kennedy Community Health Center / Burmese families New England Dream Center Opening Heaven’s Doors Ministry Group Parent/Professional Advocacy League Plumley Women’s Group South East Asian Coalition Tower Hill Botanical Garden - Garden Within Reach Women Together Worcester Refugee Assistance Program Youth and Family Services – Town of Shrewsbury Youth Connect In 2017-2018, the WRTA is actively involved in several different outreach efforts. For example, the WRTA Administrator is currently co-chairing the WRTA Riders Advisory Committee, a transportation focus group that meets monthly to “ensure that riders are part of decision-making processes and to advocate for affordable and accessible transportation.” The effort is being organized by the Worcester Community Connections Coalition, one of 22 coalitions across the state that were created in 1993 with federal funding through the Family Preservation and Support Act to the MA Department of Children and Families as part of a statewide effort to build a continuum of family support services in neighborhoods across Massachusetts. Language assistance and access to essential services is a cornerstone of their organization and client base. In addition, WRTA and CMRPC Transit staff are participating in a similar effort comprised of paratransit customers and related advocacy organizations. This group is called Future of Transportation for People with Disabilities. It is being chaired by a staff person from Easter Seals Massachusetts, and involves riders, advocacy organizations, and local officials. The next CMMPO Long-Range Transportation Plan (LRTP) will begin development in Spring 2018. WRTA and CMRPC staff will be conducting additional WRTA outreach during the document’s development in 2018 and 2019. 24 | P a g e
Finally, the Customer Services staff has been working continuously in the Service Area to assist organizations serving persons with limited English proficiency. A monthly summary can be found in Appendix A. 2.2 Factor 2: Frequency of Contact with LEP Persons As detailed in Section 2.1.2 above, WRTA employees are in contact with LEP persons on a daily basis. The following is a list of types of encounters: • walk-in customers to the WRTA’s Customer Service Center; • customer telephone calls to WRTA Information Center; • bus driver and passenger conversations; • customer surveys; • public hearings/meetings, principally for fare and service changes; • meetings with community based organizations, and • WRTA website. 2.3 Factor 3: Nature and Importance of WRTA Services to the LEP Community The WRTA is committed to making its services available and as accessible as possible to all persons living within its Service Area. The WRTA is also committed to providing opportunities for all persons to participate in transit planning processes. The WRTA is also committed to tailoring its outreach to LEP persons depending upon their proximity to, and projected use of, its services. Further, the proportion of LEP persons in its Fixed-Route Service Area exceeds the LEP proportion for its Service Area, and for the CMMPO region as a whole. Finally, LEP persons may tend to be more dependent on transit service than English speakers in the Service Area. Any denial, delay or reduction in access to WRTA services because of language-related barriers is unacceptable to the WRTA. The WRTA recognizes that thousands of persons depend on transit each day in its service region for critical mobility needs, such as traveling to medical appointments, shopping for food, commuting to work, and getting to school. The importance of public transportation to LEP constituents in the WRTA Service Area has been well documented – particularly during fare and/or service change public meetings. In addition, public transportation’s 25 | P a g e
importance to refugees in the WRTA Service Area was well illustrated by Ascentria (formerly Lutheran Social Services) in a 2016 MassDOT Community Transit Grant Program application. As previously noted, Ascentria is under contract to the WRTA to provide language assistance services and has an excellent knowledge of language assistance needs in the WRTA Service Area. 2.4 Factor 4: Resources Available to WRTA and Overall Cost The WRTA utilizes federal and state sources of operating and capital assistance for programs and services that benefit the region’s LEP population. LEP is tightly integrated with WRTA Operations and Customer Services, and is being integrated into its Marketing efforts as well. The WRTA has calculated the cost of its staff time and contracted services that support its language accessibility activities. Approximately $50,000 is expended annually for this work. Resources available to the WRTA through non-profit, state and federal agencies include, but are not limited to: • MassDOT’s Office of Diversity and Civil Rights (ODCR) • The Massachusetts Office of Public Health and Communications’ Translation Toolkit • Language assistance resources outlined in FTA’s LEP Handbook (pages 42-45) • Local non-profit organizations that assist persons with LEP (Ascentria, Centro, Worcester Community Coalition, the Refugee and Immigrant Assistance Center, Southeast Asian Coalition of Central Massachusetts and others) The WRTA will continue to identify LEP concerns and seek appropriate additional funding that may be available for LEP programs and services. 26 | P a g e
3.0 SAFE HARBOR PROVISION Federal law provides the WRTA and other FTA Recipients with a ‘Safe Harbor’ provision so that they can ensure with greater certainty that they comply with Federal requirements to provide written translations in languages other than English. In other words, a Safe Harbor means that if a recipient provides written translations in certain circumstances, FTA will consider such an action as strong evidence of compliance with the recipient's written- translation obligations under Title VI. However, it must be said that a decision to not provide written translations does not necessarily mean that the Recipient is noncompliant. For example, even if the FTA recipient does not adopt the Safe Harbor approach, if written translation of a certain document(s) would be so burdensome as to defeat the legitimate objectives of its program, said translation is not required. Other ways of providing meaningful access, such as effective oral interpretation of certain vital documents, might be acceptable under such circumstances. Strong evidence of compliance with the recipient's written-translation obligations under the Safe Harbor provision includes providing written translations of Vital Documents for each eligible LEP language group that constitutes five (5) percent or 1,000 persons, whichever is less, of the population of persons eligible to be served or likely to be affected or encountered. WRTA’s translation of other documents, if needed, can be provided orally. This provision applies to the translation of written documents only. It does not affect the requirement to provide meaningful access to LEP individuals through competent oral interpreters where oral language services are needed and are reasonable. The WRTA has employed the Safe Harbor approach in prior reporting cycles to demonstrate its compliance. For 2017, it is using 2011-2015 ACS data as a starting point and making best use of Customer Services and Operations interactions (enhanced by the use of the SalesForce tool). CMRPC Transit staff information is also used, particularly as the WRTA’s language work is relevant to CMMPO activities. Also, the WRTA has calculated the cost of staff time and production/circulation of translated documents as a guide in determining which languages to offer complete translations. The WRTA also uses MassDOT-supplied standard instructions for requesting language 27 | P a g e
assistance in the Safe Harbor languages to instruct readers to request additional information. In accordance with Federal requirements, other translations are provided upon request at no charge. To summarize, the languages that meet the threshold of 1,000 persons (but not necessarily 5% of the population) within the WRTA Fixed-Route Service Area using Census and ACS data are: Arabic, Chinese, Polish, Portuguese, Spanish, and Vietnamese. The WRTA’s Vital Documents are its: • Public Notices; • Title VI Notice to Beneficiaries, Complaint Procedure, and Complaint Forms; • Notice of Information Availability in Another Language through Google Translate; • System Map 28 | P a g e
4.0 LANGUAGE ASSISTANCE IMPLEMENTATION PLAN This section describes the WRTA’s current and future plans for providing language assistance to LEP persons in its Service Area. 4.1 Identifying LEP Persons Who Need Language Assistance The WRTA identifies LEP persons who need language assistance through the following programs, activities and services: • telephone assistance and Customer Service call center assessments; • conversational assessments of walk-in customers at the Hub’s Customer Services window; • conversations with WRTA bus operators and field personnel • inclusion of instructions for requesting language translation on public meeting notices; • work with community organizations to hold public meetings in specific locations that may require language translation and/or signing interpreter services; • review of Census data to identify likely geographic locations of potential LEP customers, and • outreach to community-based organizations and municipal agencies to ask their assistance in identifying LEP persons who may need language assistance. 4.2. Providing Language Assistance This section describes the WRTA’s current and future services that enhance LEP persons’ access to its system. WRTA service information is furnished in multiple formats such as website translation services, providing bilingual staff whenever possible, and working with partner agencies/community organizations that can assist with language translation. These services are provided free of charge to the public. The WRTA is balancing its use of Census/ACS data with surveys, staff interactions, and online tools to assess the likelihood of interactions in specific languages. Emerging languages that it will be monitoring include: • African Languages: Swahili • Asian: Chinese and Vietnamese • Indo-European: Albanian 29 | P a g e
4.2.1 Existing LEP Programs and Services The WRTA staff collectively possess language assistance capabilities that it uses to deliver programs and services. 4.2.1.1 Verbal Communication Most often, at least one of the Customer Services staff speaks Spanish. As of the writing of this Plan, four staff persons speak Spanish; in addition, one staff person also speaks French and Creole. Staff is now trained in the use of Google Translate or similar tools to assist customers, including use of an I-tablet for in-person encounters at the Hub information window. While these services are not sophisticated enough for proper grammar translation, WRTA bilingual staff will provide assistance when possible. If not possible, staff utilizes Ascentria (under WRTA contract) to provide real-time translation and other language services; the Refugee and Immigrant Assistance Center, or the Southeast Asian Coalition to provide assistance. Many vehicle operators are bilingual and/or are familiar with common phrases used by customers in languages other than English. The most recent staff survey in April 2016 yielded the following operator language capabilities as shown in Table 7 below: Table 7: WRTA Vehicle Operators Language Capability Survey – April 2016 Arabic French Italian Polish Spanish Albanian French Jamaican Portuguese Twi – Creole English (Ghana) Ashanti Greek Nigerian Somali (Ghana) In addition, professional language interpretation in Spanish is made available at public meetings. 4.2.1.2 Written and Displayed Communications • translation of WRTA policies and services using either Customer Service staff, community organizations, or other resources; • onboard announcements and Notices in English and Spanish, also a WRTA Language Brochure in nine languages spoken in the WRTA Service Area – made available at Customer Services and aboard WRTA vehicles (added in 2016); • website translation function using Google Translate (list of languages 30 | P a g e
available in drop-down menu) for customers to access on their own; • notices offering translation of key WRTA documents available in languages other than English upon request as shown below: 4.2.1.3 Translation • Chinese (Traditional): 如果此信息需要以另一種語言,請訪問 www.therta.com並使用谷歌翻譯功能。 • English: If this information is needed in another language, please visit www.therta.com and use the Google Translate feature. • French: Si vous désirez ces renseignements dans une autre langue, prière de vous server de Google Translate qui se trouve à l'adresse suivante: www.therta.com. • Polish: Jeśli ta informacja jest potrzebna w innym języku, proszę odwiedzić www.therta.com i korzystać z Google Translate funkcji. • Portuguese: Se esta informação é necessária em outro idioma, por favor visite www.therta.com e use o Google Translate. • Spanish: Si necesita esta información en otro idioma, por favor visite www.therta.com y utilice Google Translate. • Swahili: Kama unahitaji habari hii katika nyingine lugha, unaweza kubonyeza mahali panaandikwa "Google Translate" hapa juu. • Vietnamese: Nếu thông tin này là cần thiết trong một ngôn ngữ khác, vui lòng truy cập www.therta.com và sử dụng các tính năng của Google Translate. Meeting Notices include explanation of procedures to request language translation (translated into Safe Harbor languages) Customer Bulletins and information displayed in LED kiosks are translated to Spanish. Currently, the WRTA provides translated paratransit materials in Vietnamese and Russian upon request. In addition, paratransit brochures are translated into Spanish. Also, the WRTA Paratransit Riders’ Guide is available in English and Spanish. WRTA will continue to assess the utility and accuracy of the language tools that it already employs in-person, through mobile devices, and by phone. 31 | P a g e
The WRTA commits to implementing those that work best for customers and staff, subject to available funding. 4.2.1.4 Education, Information Exchange, and Training Customer Services staff regularly evaluate LEP customers’ needs and options to better serve them. For example, the WRTA defines an interpreter as a person who translates spoken language orally - as opposed to a translator, who transfers the meaning of written text from one language into another. The person who translates orally is not a translator, but an interpreter. In prior LEP/LAP documents, the WRTA reported that it engaged interpreters in just a few instances – primarily for Vietnamese, Portuguese and Spanish- speaking customers. In many instances, customers who do not speak English or do not speak English “very well” are accompanied by another person (family member, friend or community center staff) who does speak English. The current initiatives are discussed in Section 3. 4.2.2 Future Language Assistance Program Services The WRTA modifies its Language Assistance Program (LAP) following completion of a Four Factor Analysis during each FTA Comprehensive Review cycle. In general, the WRTA has expanded its LAP in each cycle to serve additional languages. The WRTA’s proposed future programs and services to enhance accessibility of transit services to LEP persons include: • continuing and expanding partnerships with community organizations to develop a list of additional language translation volunteers who are available for public meetings. This option could be used where advanced notice is provided that translator services are needed. This option may also help increase the number of languages for which translation services are available; • developing written translation and oral interpreter service providers database which would improve the speed and convenience with which written documents can be translated for the public, and reduce the need to have public requests for them; • using CMMPO LEP services outlined in its LEP plan, as developed; • ensuring other CMMPO members are aware of the U.S. DOT’s LEP 32 | P a g e
You can also read